Last Updated: February 1, 2019
This privacy statement does not apply to Boku Identity’s consumer customers accessing and using our website, nor are such customers deemed to be third party beneficiaries of this privacy statement.
WHAT WE COLLECT AND HOW WE USE IT
When interacting with Boku Identity’s PVS sites, or when contacting Boku Identity for PVS support or information.
INFORMATION YOU MAY SUBMIT
When you contact us for PVS information, support or otherwise send us information via our website in connection with PVS, we collect the information you provide us in your submission or communication, such as your e-mail address, name and contact information, information about the reasons for your communication.
When you browse our PVS websites or request pages, we automatically collect certain technical information about your visit. Examples of this standard type of information include the type of Internet browser you use, your IP address, browser headers, browser types (i.e. desktop or mobile), the files you request, and the domain name and country from which you request information. We use this type of technical information to make our PVS website function correctly, to better understand how visitors use our PVS website, and to improve the PVS website, its contents, and functionality to meet your needs. As part of our efforts to protect customers from fraud, this information is also used to assist in authenticating who you are when you access the PVS website.
Some of our PVS web pages may contain “cookies”, or data that is sent to your web browser and stored on your computer. The purpose of these “cookies” is to allow our server to recognize you as a Boku Identity customer if you return to the website using the same computer and browser. In the event you do not wish to receive such cookies, you usually may configure your web browser to not accept cookies or to notify you if a cookie is sent to you. You are free to decline cookies if your web browser permits, but you may not be able to use all the features and the functionality of our websites. Boku Identity does not link the information we store in cookies to any personally identifiable information you submit while on our PVS website.
HOW WE USE IT
We use personal information collected when you contact us or interact with our PVS websites in a number of ways such as to respond to your communication, address any problems brought to our attention, to better understand and manage our ongoing relationship with you, to assure good service, to prevent fraud and abuse, for purposes of verification and risk management, to improve our services and websites, and otherwise with consent or as permitted or required by law.
Boku Identity may store personal information on databases for the purposes of the administration of our business, including our ongoing relationship with you, for market research and, only with your consent, for direct marketing purposes. As permitted by applicable law, we may merge personal information with public information or other information received from reputable vendors to update contact information or to enhance demographic profiles.
We may share all of the information, as described above, with our affiliates, customers, and our agents in connection with goods and services these parties perform for, or with, Boku Identity for the uses described in this policy and for other purposes as permitted or required by law.
In particular, use of your personal information for marketing purposes by Boku Identity and/or our agents will always be made with your consent and in compliance with the applicable law regarding customer consent. Disclosures permitted or required by law may include cooperation with criminal or government investigations, fraud prevention and detection, and responses to a court order or subpoena. Boku Identity agents are bound by appropriate data safeguarding obligations.
When interacting with an application or service that accesses or uses Boku Identity’s Phone Verification Services (“PVS”)
PHONE VERIFICATION SERVICES
Boku Identity provides PVS to merchants that may have a need to verify their customers for the purpose of fraud avoidance. To provide PVS, Boku Identity utilizes data or information obtained from merchants, mobile carriers and other data sources.
When you use PVS, you and other third parties may provide Boku Identity with personal information about your customers. This personal information may include information related to mobile telephone numbers, such telephone numbers’ validity, type (e.g., mobile, landline, VOIP), corresponding device status (e.g., is it available for messaging), roaming status, carrier, country of location, and whether or not the number has been ported.
Boku Identity receives information about communications sent and received using PVS. For example, when an SMS is sent or replied to via SMS, Boku Identity receives, collects and maintains information related to the SMS and other message transmissions and conversion data (e.g., receipts, phone numbers, size, time of transmission, confirmations, data, etc.), which may include, among other things, your customers’ personal information.
PVS routes inbound and outbound communications between merchant and Boku Identity through third party mobile networks, aggregators and database providers, and they may transmit data to their respective service providers in the transmission channels. Boku Identity will share your communications and related information (which may include your or your customers’ personal information, including their telephone numbers and related information) only to the extent it is related to the PVS, and Boku Identity may obtain and disclose to you information obtained from our third party providers, including information on a telephone numbers’ validity, type (e.g., mobile, landline, VOIP), corresponding device status (e.g., is it available for messaging), roaming status, carrier, country of location, and whether or not the number has been ported.
Merchant represents and warrants that if it provides any personal information from any of its customers in using PVS it has any such customer’s consent to do so and that such customer’s consent permits Boku Identity to collect, process, use and store their personal information for the purpose for which you have sent it. Further, in providing such customer information, merchant represents and warrants that it adheres to the principles of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, as amended (commonly known as the General Data Protection Regulations, or “GDPR”) for personal data that it receives from the EU member countries.
While possibly redundant, our participating mobile carriers have asked us to pass along this important message:
General Policies – When Data is Retained or Processed by Us under the Above Policies
To the extent personal or consumer information is retained by Boku Identity (e.g., in cases involving use of our websites, social media sites, etc.), if Boku Identity becomes involved in a merger, acquisition or any form of sale of some or all its assets, we may disclose personal information to third parties in connection with the evaluation of the transaction. The surviving company, or the acquiring company in the case of a sale of assets, would have access to personal information that would continue to be subject to this privacy statement.
Boku Identity will not use or share your or your customers’ personal information in ways incompatible with the ones described above.
For cases where we may retain personal information (e.g., in cases involving use of our websites, social media sites, etc.), the subject must opt-out of any sharing of personal information it has authorized or consented to as described above. However, to the extent that applicable law requires express consent or “opt-in” for the collection and use of personal information, Boku Identity will maintain processes and procedures to ensure such information is collected with express consent. Personal information will not be used to directly market Boku Identity services unless that possible use of the information has been disclosed and a choice provided. Users have the opportunity to opt-out of receiving communications from us or to remove your information from our database at any time by emailing firstname.lastname@example.org with your specific request.
Boku Identity utilizes physical, electronic and procedural security measures to protect against loss, misuse and alteration of information under our control. Boku Identity offers industry standard practices and security measures to safeguard and secure the personal information we collect or process.
Access to personal information is restricted to employees, service providers, and mobile carriers who need to have access to that information as described in this privacy statement. Boku Identity requires its service providers to observe standards with respect to the security, collection, use, and sharing of personal information, and to comply with applicable law. We make reasonable efforts to ensure security on our systems. Despite our efforts, we cannot guarantee that personal information may not be accessed, disclosed, altered, or destroyed by breach of our administrative, managerial and technical safeguards. When you enter sensitive information such as your mobile number, we encrypt that information using secure socket layer technology (SSL).
If Boku Identity learns of a security systems breach we may attempt to notify you electronically so that you can take appropriate protective steps. Boku Identity may post a notice on the Boku Identity website if a security breach occurs. Boku Identity may also send you an email to you at the email address, if any, you have provided to us or send you an SMS to the mobile number you have provided to us.
Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice of a security breach) you should notify us email@example.com.
PREVENTING IDENTITY THEFT
Boku Identity is dedicated to protecting your personal information. We will never initiate a request for personal information from you by fax or email.
Please do not send confidential personal information such as social security numbers, government identification numbers, or account numbers to Boku Identity via an unsecured email message. You may send confidential information to Boku Identity via posted mail, phone or contact us at [ ].
Do not be misled by emails that appear to be from us and ask for personal information. If you receive a suspicious email requesting your personal information, please forward the email immediately to firstname.lastname@example.org. To report fraud to the Internet Fraud Complaint Center, visit www.ic3.gov. This is a partnership between The FBI and the National White Collar Crime Center.
PRIVACY PRACTICES OF THIRD PARTIES
Boku Identity is not responsible for the content or information practices employed by other websites that are linked to or from our website. In most cases where links are provided, they are provided as pointers to information on services that may be useful to users. You are encouraged to review the privacy statement of these other websites before providing them with personal information.
THIRD PARTY COOKIES
USE BY CHILDREN
Boku Identity will not knowingly collect personal information from children under the age of 13, without the consent of a parent or guardian.
CHANGE IN PRIVACY STATEMENT
We reserve the right to modify this privacy statement at any time, so please review it frequently. If we change how we use your personally identifiable information, we will notify you here, by email, or by means of a notice on our homepage.
By using our websites, social media sites or by contacting us and providing us with data, you acknowledge and agree that due to the international dimension of Boku Identity we may use the data collected in the course of our relationship for the purposes identified in this policy or in our other communications with you, including the transmission of information outside your resident jurisdiction. Please note that personal information will be stored and processed on our computers in the United States. While Boku Identity generally adheres to the principles of GDPR with respect to information received from EU countries, you shall be responsible under GDPR for your customers’ personal information unless and until you and Boku Identity enter into a separate agreement delineating our respective responsibilities as joint controllers with respect to your customers’ personal information.
CALIFORNIA PRIVACY RIGHTS
California Civil Code section 1798.83 permits customers who are California residents to request certain information regarding disclosure of personal information to third parties for their direct marketing purposes. We do not provide your personal information to any third party for their direct marketing purposes without your consent. If you would like more information with respect to your privacy rights under California law, you may contact us at the contact point below. Please reference your request as “California Disclosure Information.”
FOR MORE INFORMATION OR IF YOU HAVE QUESTIONS
Should you have further questions regarding our privacy statement or about how your personal information is used, you can contact us at:
Boku Identity, Inc.
Address: 2833 Junction Ave, Suite 202, San Jose, CA 95134